Friday, July 13, 2018

Take Compliance Seriously- Or…It Will Cost You!

Take Compliance Seriously- Or…It Will Cost You!In the News

Recently, some scary EMS articles have been published. Here are some headlines…

Fla. Ambulance company to pay 1.2M in federal whistle-blower lawsuit

<Company name redacted> settles Medicare fraud suite for 12.7M

Ambulance company owner sentenced to prison for fraud

Feds crack down on Medicare ambulance fraud

Get the Picture?

Do you get it?

Everyone connected with Emergency Medical Services in America needs to sit up and take notice. If you are swimming in the murky waters of ignoring compliance issues, then you are about to be gobbled up by the hidden shark in those waters.

And…the bite you are about to receive is going to hurt, badly. 

None of us who live in this world of all things EMS, especially in the ambulance billing world can ignore how important maintaining strict compliance guidelines is for us. For a long time, there have been those in our industry who thought they were getting away with bilking the entitlement programs out of millions of dollars by “juicing up” documentation, resulting in claims submitted to Medicare, Medicaid and even commercial insurance plans that were anything but compliant.

It’s the end of the road for them.

Wake-Up Call

One of the biggest wake-up calls was the inception of the Medicare Prior Authorization for Repetitive, Scheduled Transportation Demonstration Program.

On Day One of the inception of this trial program, the areas covered by the demonstration- those geographic areas showing the highest over-utilization statistics- saw a drastic decrease in the reimbursement dollars flowing from Medicare.

Of course, we all saw whole ambulance companies padlock their doors and certainly there was quite a debate regarding the program and the impact on access for patients in some rural areas given the loss of services. Yet, now that the dust has settled in the demonstration program States, it seems like life has found a new normal and the chance for those ambulance operators who were operating under-the-radar committing widespread abuse of the system has diminished greatly.

Much to the delight of the Feds, the program worked as intended spotlighting activity that was detrimental to the Medicare system as a whole.

What to do?

So, you’re an ambulance company’s administrator and you read all of the articles and suddenly you have this strange feeling in the pit of your stomach…what do do? 

Are we safe? Is my company following all of the rules? How can I be sure?

Relax…there are ways to ensure that you’re coloring between the lines.

Get Help!

First off, there are experts out there that can help you. 

Get help!

No one of us can be experts in everything we do. There are those who specialize in all things compliance. Find them…engage them…work with them. Find a partner to help you review and audit all things billing and compliance related. Seek out those individuals and/or companies who can help you be compliant.

The days of going it alone in this business are far gone. You cannot take chances, especially if your run volume is of any size. One repeated mistake in billing can be multiplied over hundreds of claims. If undiscovered, by the time you identify that you have a problem many dollars may have flowed to you from Medicare, Medicaid and/or insurances that you are now liable to re-pay in order to keep you out of trouble.

Compliance is not a one-time thing. It must be a living, breathing, on-going dynamic part of your everyday EMS life just like everything else you do daily be it in the field or in the office.

Consider Outsourcing

Okay, so maybe Mabel has been your “billing person” since 1980-something and you love her to death. 

We understand.

But, have you been able to keep Mabel up-to-date on the latest and greatest in EMS billing and compliance? Quite frankly, do you even have a written compliance program backed up by continual audits and monitoring? Or is your compliance program simply a binder with a foot of dust on it, somewhere to the far corner of your office shelf?

Is Mabel a certified coder? Has she been keeping up on the new rules and regulations or have you just not had the time and money to help her achieve your compliance goals?

An outsourcing company, like our company here at Quick Med Claims, can help! 

You can be assured that our company has, not only the certified people, but also the processes and procedures in place to closely monitor your compliance- submitting each and every claim in compliant fashion.

Is it time to consider outsourcing? 

If your answer is “Yes” then avoid becoming the next headline and contact our office today. 

Then tonight…rest easy. We got this!

Friday, June 29, 2018

Ambulance Industry Legislation Update

In this space…

Over a few month we reported in this space about legislation in several States that had the potential to impact the ambulance industry in a big way.

Since those posts, there have been some positive developments on a few fronts.

Ambulance Industry Legislation UpdatePennsylvania Legislation Passes

The new State budget passed with little fanfare in the Commonwealth of Pennsylvania. Dubbed House Bill 2121, the bill passed easily in a State where budget bills often cause heated discussion and prolonged passage delays.

The new budget incorporates the provisions of the aforementioned House Bill 699 ushering in a 50% increase in Medicaid reimbursement for the first time since 2004. The increase will take effect January 1, 2019.

Basic Life Support transports will now be paid at a base rate of $180 per transport, up from the previous $120. Payment for transporting at the Advanced Life Support level will increase from $200 per transport to $300.

New York Legislation Push Advances

While legislation allowing fire-based EMS to bill and collect reimbursement in the State of New York has yet to pass, the word circulating at Fire 2018, the annual New York State Association of Fire Chiefs (NYSAFC) conference, is that there has been headway made in talks to advance the legislation in the Empire State.

As we reported previously, New York statute prohibits fire-based EMS from billing. The NYSAFC and others are strongly pushing for this moratorium to be lifted, allowing fire departments with an EMS component to bill for their services. Citing a growing number of fire departments mothballing EMS, with negative effect on smaller, remote communities noticeable; the legislation is being championed as a “rescue effort” for EMS in those community fire departments.

Word from the floor at convention headquarters in Verona, New York, is that discussion between the NYSAFC and State lawmakers is advancing with compromise verbiage being discussed on some of the finer points of the final language in the bills (Assembly and Senate.)

CMS Holds Data Collection System Listening Session

This week, the Centers for Medicare and Medicaid Services (CMS) hosted an audioconference listening session as the first step in response to Congress passing the Bipartisan Budget Act (BBA) of 2018.

You’ll recall that Section 50203 of the BBA of 2018, brought an extension of the Medicare ambulance add-on payments through 2022. However, with that extension comes the Congressional mandate for CMS to begin the process of developing a method for collecting cost data from the industry.

The statute calls for Ground Ambulance Providers and Suppliers to submit information detailing their costs. CMS must collect cost, revenue, utilization and other information determined appropriate by the Secretary of Health and Human Services (HHS) and submit the report to Congress. The Act mandates CMS to specify the data collection system that will be used and who must report by no later than December 31, 2019.

The listening session was meant to gather on-the-record testimony from industry stakeholders regarding their thoughts on what data is to be collected and the method for collecting it. While CMS is not bound to follow these recommendations, it was well-received by those participating that CMS opened the door for input from the industry up front and prior to making a final decision on the cost data collection process.

Synopsis of Comments

Numerous comments were entertained during the listening session call. Some of the most notable included these suggestions.
  • Nearly all those who commented applauded the announced CMS decision to not use the existing hospital cost reporting mechanism. Those commenting agreed that the hospital data collection process would not serve the ambulance industry adequately for this mandate.
  • One commenter asked CMS to insure to have a mechanism in place to filter out the non-cost of volunteer labor. The commenter asked for a data collection floor of a minimum of two full-time employees to be the benchmark so to not negatively skew cost data collection results by including all- or mostly-volunteer staffed EMS agencies with zero labor costs.
  • It was requested that CMS gather cost data that includes the costs for EMS to treat patients who do not require transport.
  • One caller asked CMS to consider, in their final analysis, how the Medicare Fee Schedule not only impacts the American ambulance industry directly through Medicare program reimbursements, but also to take into account how many commercial payer sources base their ambulance reimbursements fee schedules on the National Medicare Ambulance Fee Schedule.
  • There was a request for CMS to devise a means to factor in local government-based EMS department costs which the commenter explained are subsidized by tax dollars, potentially affecting the cost picture for those entities. The concern by this caller was that local tax dollar supported EMS providers would potentially lower the final cost report due to those locally-collected subsidies.

Friday, June 8, 2018

Legislative Initiatives Poised to Benefit EMS in Three States

PA, NY and MD

State lawmakers in Pennsylvania, New York and Maryland have been working on new legislation that has the potential to drastically change the EMS reimbursement landscape.

Legislative Initiatives Poised to Benefit EMS in Three States

This year has seen a flurry of activity in the chambers of government across these States as fire and EMS advocates are sounding the alarm regarding stagnant reimbursement rates that are failing to keep pace with the growing costs to provide EMS services.

While Pennsylvania and New York lawmakers are still considering future passage of their initiatives, their counterparts in Maryland have successfully pushed legislation that has now been signed into law by that States governor.


Maryland Senate Bill 682

On May 15th, Governor Larry Hogan signed into law Senate Bill 682. The new law will be enacted officially on July 1st.

This new law charges the Maryland Institute of Emergency Medical Services Systems (MIEMMS) and the Maryland Health Insurance Committee to initiate a 6-month study for report back to the State Legislature to devise a plan that will require commercial insurance payers and Maryland Medical Assistance to pay for the following…
  • Mobile Integrated Health Care (MIHC)
  • Treatment of a patient on the scene but with no transport required
  • Transport of a patient to an alternative location that is not a hospital destination
The bill calls for a comprehensive plan to be submitted as part of the report including a plan for how such reimbursement will be obtained from the Medicare program, as well.

Under consideration, as part of the study, is for the Maryland Medical Assistance program to initiate a rule change so Medicaid payments can begin on January 1st. The Medicare issue, while tied up in Federal initiatives may be tackled under a waiver program set to take effect also on January 1, 2019 which includes a “total cost of care” initiative.


Pennsylvania Senate Bill 1013 / House Bill 699

Legislation spearheaded in Pennsylvania by a State lawmaker with direct EMS ties has been passed just this week in the Pennsylvania Senate. Senate Bill 1013 was approved by the upper chamber, putting into motion a series of events that will require Pennsylvania Medicaid and commercial insurers to reimburse EMS agencies when emergency treatment is provided at the scene but transportation is not required.

State Representative Martin Causer of the 67th Legislative District encompassing Potter and McKean Counties in the Bradford and Coudersport areas of the State is leading the rally complete with House Bill 699. Causer, a former EMS provider himself, has been a champion for this legislation. This week he organized a rally of EMS representatives in Harrisburg which later resulted in the passage of SB 1013.

HB 699 takes another pathway to improving reimbursements for Pennsylvania’s ambulance industry. The bill proposes a 50% increase in Pennsylvania Medicaid reimbursements, which would be only the second such fee update since Medicaid began reimbursing for ambulance transportation in Pennsylvania.

As the overall discussion of the thinning ranks of fire and EMS personnel in Pennsylvania gains traction, these initiatives at the State government level will help ease some of the concerns for EMS administrators across the Commonwealth.


New York S0363 / A7717b

With a heavy push by the Fireman’s Association of the State of New York, the New York State Association of Fire Chiefs and the County Fire Coordinators Association of the State of New York, two bills have been introduced that are mirrored in nature. In the Senate S0363 and in the Assembly A7717b were introduced earlier this year with focus on allowing Fire Departments in that State to recover the costs of EMS services.

The move has gained traction as championed by several North Country lawmakers who growingly have become concerned regarding fire departments in that geographic corner of New York expressing concern over growing budget shortfalls when providing ambulance services.

New York State has always had a moratorium in place prohibiting recovering reimbursement for EMS services by fire departments. For perspective, consider that of the 1,025 ambulance services in New York State, 468 of them are fire-department based accounting for 300,000 calls for service each year.*

The legislation has gained considerable headway over the past several weeks with the Senate moving S0363 into both the Local Government and Finance Committees while the State Assembly has Advanced A7717b through to their Local Government committee.


Every Penny Counts

We all know that every penny counts. Lawmakers are faced with the pressure of passing initiatives that will support vital emergency services while at the same time balancing a tight revenue stream that does not inordinately raise taxes for their constituents.

We will continue to follow these important pieces of legislation as they advance in these States. Certainly, there will potentially be other State lawmakers across the nation who will look to their counterparts for the overall outcome.

*The article, ”Bill would allow fire departments to recover costs of EMS services” published by The Legislative Gazette on 5/22/2018 is the source for New York State ambulance service statistics reported above.

Friday, May 25, 2018

Ordinary People Doing Extraordinary Things

Amazing!

You are amazing!

You- yes, you…Mr, Ms, Mrs…paramedic, EMT, nurse, doctor….ground-, air-based…you are amazing!

In case no one told you that in the last week as we celebrate EMS, please allow all of us here at Quick Med Claims to pat you on the back and call you out for the hero that you are.


It Doesn’t Matter…

It really doesn’t matter what role you play nor how long you’ve been involved in EMS. You matter! You are a big deal!

From the folks in the air, on the street to those in the office and especially those of you who volunteer by giving your time, knowledge and expertise in whatever role you play; just know that while you may not hear this every day from those you serve- they definitely appreciate you.

We appreciate you!


Look How Far…

Look how far EMS has come.

As first responders to all things medical transportation-ish we have made enormous strides. Everyday lives are saved because those who came before us were willing to think outside of the box and come up with new ways and new equipment, and might we say new money, to develop a constantly evolving and every-changing new system to make this all happen.

Our list of incredible “toys” has grown, but more importantly you all have grown. The skill and education that today’s EMS requires is mind-boggling. It takes you to make that cardiac monitor transmit a digital image to the ER doctor. It takes you to properly apply the Lucas Tool to deliver flawless and consistent chest compressions. It takes you to get the IV started in a moving vehicle with potholes and bumps and turns and twists, administer the correct medication in just the right dosage that saves the life and preserves a family yet another day.

Maybe you’re the new Community Paramedicine paramedic. Your visit to Mrs. Jones’ house to look in on her may just be the only visit she receives today. You leave with the satisfaction that this widow can rest knowing she has achieved her health goals for the day plus she’s a bit less lonely for your having stopped by. Mobile Integrated Healthcare at its finest and you’re the pioneer on the forefront.

We can go on and on…you know who you are.


The Nasties!

On TV, the Station 19 crew always has the “big one” and it always works out in the end.

Fast-forward…real world…not so much.

For every “big one” there are ten “not-so-big-ones”…like the trip from the ER discharging to the SNF. Or there’s the guy who had a few too many tall ones that pukes on your nicely mopped ambulance floor which now you’ll mop and disinfect again.

There’s the brand new uniform pants that now has blood on them and it won’t come out.

There’s the overdose victim that lives for another day because of that vial (or two) of narcan the wonder drug that you just administered and while you feel relieved that he lives, somehow you know that you’ll be back again tomorrow at the same location for the same patient. So…you provide a bit of fatherly/motherly advice; “Get help!”…and yet help evades these people over and over.

But you keep going. Though the nasties, through the routines and the not-so-routines.

You keep going on and on missing lunch, stretching those bathroom breaks to the point of explosion and you do it on two hours sleep here and there. Along the way, you struggle to take care of yourself- try to eat right, try to forget, try to cope and yet you still feel the rush when you know that you completely stood up to death and you won!


Unless you do it…

From the billing office window, we are in awe of you. We see first-hand what you do and are continually amazed at your accomplishments. You are a true superhero in every sense of the word.

Unless you do this thing that we all do, be it in the office or in the field; few people outside of the first-responder world will ever really “get” why and how you do it. To them you may just be an “ambulance driver” but to us you truly walk on water.

But, what really amazes us is the fact that you take it all in stride. It’s another “day at the office” and yet countless people enjoy another day of life because of YOU! That’s a big deal!

THANK YOU! As we close out this EMS week, we truly say THANK YOU!

You rise with humanity to permanently impact the lives of everyone you touch. The debt of gratitude that society owes you is immeasurable.

Be safe! Happy EMS Week!!